' Detail-Savvy Long Beach Resident Kerrie Aley Sends Mayor/Council This Email, Citing Gov't Figures, Says Numbers Show City Staff's LUE <u>Overstates</u> Housing Need, Flawed In Demanding Increased Density; She Offers These Solutions

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Detail-Savvy Long Beach Resident Kerrie Aley Sends Mayor/Council This Email Citing Gov't Figures, Says Numbers Show City Staff's LUE Overstates Housing Need, Flawed In Demanding Increased Density; She Offers These Solutions

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(March 6, 2018, 8:00 a.m.) -- On March 5, Long Beach resident Kerrie Aley sent Mayor Garcia, all LB City Councilmembers and senior city planning staff an email citing data from official sources that she says show city staff's Land Use Element (LUE) housing numbers are flawed and overstate housing need in demanding increased density.

In late 2017, Ms. Aley sent city staff an email raising a number of these points, in response to which she received a politely unresponsive response. When LBREPORT.com learned of this, we asked city staff about the points raised by Ms. Aley's 2017 letter and likewise received a politely unresponsive response.

Ms. Aley tells LBREPORT.com that she was among invited attendees at a March 3 "roundtable discussion" on the LUE with Mayor Garcia and Councilwoman Suzie Price at which she was allowed to discuss other issues but effectively prevented by Mayor Garcia from pursuing details of her numerical allegations in the roundtable format. Instead, Ms. Aley says the Mayor invited her to discuss her points after the meeting with Assistant City Manager Tom Modica (a meeting attendee); Ms. Aley says she did so; Mr. Modica listened carefully but had no immediate explanation.

Ms. Aley research and compiled the data below at her own time and expense. In the public interest, LBREPORT.com publishes the points raised by Ms. Aley in her March 5 letter to Mayor Garcia, the City Council and senior city staff. As of the morning before a City Council hearing on city staff's desired density increases, to our knowledge Ms. Aley has received no response from any of LB's electeds or city staff on the points raised in her correspondence.

[Scroll down for further.]

[Ms. Aley email text]

Long Beach City Council and Mayor,

Please find below information on the LB RHNA progress and the proposed LUE. The City has already met the SCAG 2040 requirement for above moderate housing units to 2040. The city needs to build approximately 1170 moderate and 2400 low/extremely low income units. The city will not provide actual proposed LUE units and I believe this number is many factors higher than what is needed.

The city should encourage more adaptive senior housing as there is a growing need. Senior housing will accommodate existing community members needs (with limited traffic & parking impacts) and allow family members to remain close by.

I believe the numbers produced by SCAG can be met with the existing Downtown and Mid-Town PDs. The proposed LUE EIR should consider a no change alternative that uses the existing un-built development capacity including current zoning/grannie flats and PDs along with the Placetypes Urban Design Element. One of the alternatives in the draft LUE EIR (caps heights in downtown LB) should be removed with another alternative that considers the SCAG requirements & real Housing Element Progress.

According to SCAG Long Beach is not extremely overcrowded and is 46th with many many other cities in Southern CA that have similar statistics. There is no State or County requirement to add 21,476 housing units to fix overcrowding. (No other city is doing this). The LUE does not specify income level and does not directly address overcrowding anyway. The SCAG RHNA numbers already consider area job growth projections (.67% per year).

Our city's infrastructure cannot handle the proposed increases in traffic, parking, utilities. The public will not accept the associated loss of quality of life impacts such as traffic safety, crime, pollution, and noise. Traffic and Parking will no longer be considered a environmental impact requiring mitigation (Per CEQA SB743). Future Project traffic/parking impact appeals to Council will not be available to citizens.

Use the existing Land Use plan goals as a guideline for future growth- new units in planned areas with existing high density. Any other additions to the existing LUE and Zoning should provide measurable neighborhood community benefits- that are supported by the people who already live in those neighborhoods. Protection of historical neighborhoods should be a priority above height/density increases. The City has used variances in the past and in some cases this has resulted in better developments (with the appeal process in place).

The proposed LUE and rezoning land entitlements will inflate future development costs. Organic growth & progressive progress LUE with a variance exception will result in controlled better planning and avoid over development boom bust problems.

Please find below research on this issue and some suggested changes to the proposed LUE and related processes.


  • Shorter time-frame 2028 for LUE, cut number of rezoned properties and 5 year reviews.

  • Similar to Mobility Element CIP include proposed vetted list (not a legal requirement but as suggested future zoning changes that requires an LUE update).

  • Set up residential permitted parking in parking impacted areas.

  • Incremental update of LUE in response to Housing Element Progress reporting.

  • Require rigorous auditing of Housing Element Progress and Economic feasibility/benefits reports. Reports should be complete, unbiased and include statistical error rates and assumptions.

  • Additional housing over SCAGG RHNA must have neighborhood community supported benefits. Any variances to zoning would have to go through public appeal process.

Here are the facts:

Proposed LUE cannot predict the future.

Current stats: American Community Survey (Census)

Vacancy Rate Steady at 3.8-4.6 +- .4-.6 % Between 2010-2016 same within error rate

1.0 Or less87%87%Delta between 2010 and 2016 same within error rate
1.01 to 1.57.4%7.2%Delta between 2010 and 2016 same with in error rate
1.51 + 4.7%5.4%Delta between 2010 and 2016 +1288 units overcrowded

Long Beach is 46 on SCAG list of overcrowdedness [see data below]

The housing crisis in LB is overstated. Primarily a wage problem.
2016 Housing Element Update
Growth rate between LA (5.6%) and LB (2.8%) 2000-2016 LB Half of LA Displacement gentrification

SEASP EIR Housing stated that in 2016 rents had risen to proportionately to income gains.

SCAG RHNA 2014-2016

Income GroupRHNA 2014-2040Progress 2017 Housing UpdateNeed
Extremely/Very Low17733211452
Above Moderate30391328
Only shows 363- 2017
4500 units downtown recently built or finished in near future
Met 2040

City does not specify how many potential new units are permitted in proposed LUE.
Does not account for state mandated increased density and bonuses.
Existing proposed EIR Traffic analysis is based on SCAG 2040 RTP population growth ....not actual LB proposed unit increases with + 21,476 units overcrowding.
The traffic analysis flow model fails at LOS E and cannot predict actual intersection delays. City has no idea what level of gridlock is proposed.
No requirement to add 21,476 to fix overcrowding. (No other city is doing this)

Beacon LBDC analysis showed only 20% of allowed units built. (Did not consider PD opportunities or new legislation and affordable housing funds) What is city's assumption for % built.

Proposed Changes to LUE


Shorter timeframe 2028 for LUE cut number of higher density rezoned properties.
Similar to Mobility Element CIP include proposed vetted list (not a legal requirement but as suggested changes)
Set up residential permitted parking in limited areas.
Incremental update of LUE in response to Housing Element Progress reporting.
Require rigorous auditing of Housing and Economic feasibility/benefits reports.
Additional housing over SCAGG RHNA must have community supported benefits.

SCAG Overcrowded Cities

SCAG Overcrowding Total  SCAG >1.01 person per room
1	Huntington Park city          	35.67%
2	Cudahy city                   	34.92%
3	Bell Gardens city             	34.55%
4	Santa Ana city                	32.14%
5	Maywood city                  	31.79%
6	Lynwood city                  	31.06%
7	South Gate city               	27.63%
8	El Monte city                 	25.67%
9	Bell city                     	25.60%
10	Compton city                  	25.13%
11	South El Monte city           	24.68%
12	Commerce city                 	23.08%
13	Baldwin Park city             	21.89%
14	Paramount city                	20.32%
15	Hawaiian Gardens city         	20.07%
16	Pomona city                   	20.02%
17	San Fernando city             	19.98%
18	Rosemead city                 	19.12%
19	La Puente city                	18.48%
20	Stanton city                  	18.12%
21	Montclair city                	17.71%
22	Santa Paula city              	17.04%
23	Anaheim city                  	16.63%
24	Avalon city                   	16.58%
26	Garden Grove city             	16.43%
26	Hawthorne city                	15.95%
27	Pico Rivera city              	15.88%
28	Norwalk city                  	15.71%
29	Lawndale city                 	15.03%
30	La Habra city                 	14.97%
31	Coachella city                	14.84%
32	Rialto city                   	14.51%
33	Azusa city                    	14.45%
34	Los Angeles city              	14.07%
35	Perris city                   	13.91%
36	Inglewood city                	13.63%
37	Oxnard city                   	13.58%
38	Montebello city               	13.51%
39	San Bernardino city           	12.83%
40	Calexico city                 	12.80%
41	Unincorporated                	12.80%
42	Ontario city                  	12.78%
43	Fontana city                  	12.70%
44	Artesia city                  	12.55%
45	Calipatria city               	12.47%
46	Long Beach city               	12.40%
47  Bellflower city               	12.35%
48  Los Angeles County              12.03%
49  Westminster city              	11.75%
Downey city                   		11.69%
Colton city                   		11.45%
Industry city                 		11.38%
Adelanto city 	                	11.37%
Buena Park city		               	11.33%
Fillmore city                 		11.20%
Indio city                          11.15%
Moreno Valley city                  11.14%
Santa Fe Springs city	         	10.91%
Highland city 	                	10.52%
Unincorporated	                	10.35%
Fullerton city	                	10.30%
Duarte city		                   	10.26%
San Gabriel city     	         	10.02%
Desert Hot Springs city 	      	9.97%
Orange city		                   	9.80%

Source: http://rtpscs.scag.ca.gov/Lists/Overcrowding/AllItems.aspx






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